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AFFIDAVIT OF LESTER SMITH

My name is Lester Smith. I live at 108 Sandra Drive, Azle, Texas 76020.

I began working at the Comanche Peak nuclear power plant in March of 1979,

as a pipe fitter. I stayed down there three months and quit about June of 1979.

I had an excellent work record when I quit and was offered a foreman's job on

the day that I left. I left because I was just fed up with it. I had been used

to working a full day's work for a full day's pay (a hard dollar job, where you

earn your money). The last day I was there, my crew (me,- and a fitter, and a

welder) sat for eight hours and there were three tack welds made in that period

of time. This was on the Unit 2 steel stainless liner (I'm not sure what the

liner was for now - I don't remem ter exactly after all this time), and we had

to wait for another craft to come up and do the cutting and drilling of holes

before we could do anything else to it. We only had time to make the three

tack welds before the end of the day.

Before that, I waited twenty-four hours for the ANI (authorized nuclear

inspector) to come look at an arc strike on a pipe. In other words. it was

twenty-four hours between the time he was called and the time he showed up,l I had to stay there because I had to be there if and when he showed up, but

I didn't have anything to do. My foremtn knew about it, but that's the way'

the rules were set up and there was nothing he could do about it either. This

was typical of the way things were down there. I sat there about ten hours.

I stayed gone four months, then went back down to Comanche Peak in October,1979.

I came back because of money. I just couldn't make as much money anywhere else

in this area as I could at Comanche Peak. I was there about three weeks or so

when they offered me a foreman's job again. This was a pipe fitter and welder

foreman's job. At that time the General Foreman down there was Wayne Dennis.

8301200259 830124PDR ADOCK 050004450 PDR

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This time I took the foreman's job. During about late 1979 and early 1980,

the as some problem about Brown & Root not producing enough to suit TUSI.h 're

My foreman, Wayne Dennis, told me to start making 3/4" socket welds so that3

we would be able to increase our production to hundreds of socket wclds each

day. This would make our' production look better to TUSI and they would go ahead

and give Brown & Root the money to go on, according to wh6t my general foreman

told me. Supposedly this came to him from Gene Everso'n (not sure of spelling),

who was pipe superintendent. Wayne Dennis used the term something like""We're

gonna blow smoke on TUSI" but he said it in more vulgar terms. And apparently

it worked and TUSl turned loose the money.

I had the foreman's job about two or two and a half months, then I told

Wayne Dennis I wasn't satisfied with it and wanted to go back to being lead

man if it was all right with him. He said it was all right and I went ahead

and finished out the week (that was on a Wednesday). After that I was a lead

man until I had to have an operation. The last day I worked that time was 6/5/80.

On my Tennination Interview form, it shows that nt/ performance rating was EXCL.

(excellent) . It was signed by my inmediate supervisor, Dave Frederick.

I was off a couple of months for my operation and recovery. I called

Brown & Root and told them I'd like to come back to work (I was on an official"leave of absence). Terry Easton, who was a General Foreman in Unit 2 (the

same category as Wayne Dennis was for Unit 1), referred me to Gene Everson

and said I was on the lay-off list. He said he would have Gene Everson call

me. Gene Everson never did call. When I called back down there late that

| afternoon, I couldn't contact either one of them. The next morning, I called

Doug Frankum's office (the Brown & Root Project Manager). He wasn't in and.

his secretary had Charlie Scruggs (who was known as "two-check Charlie" because

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he was noted for firing people and giving them both checks) call me. He told

me that I was laid off and I told him that I was on an official leave of absence

from the Brown & Root Houston office. He said that being on a leave of absence

didn't guarantee me a job. I said 0.K. and wrote Houston about my R&S (retirement

and savings) and they wouldn't let me have it while I was on a leave of absence

even though the local Brown & Root office was showing me as being laid off. I

had to wait about six months before I could even file for my R&S.

I went to work somewhere else and went back down there to Comanche Peak

in about July of 1981. They hired me back then as a pipe fitter. Buck Hill,

who took Terry Easton's place as General Foreman in Unit 2 (or they might have

had another General Foreman in between times), told me that he would put in for

me to be lead man if I did a good job after a couple of months or so. I told

him at that time that Gene Everson wouldn't sign it. He said something like

"He will if _I_ take it to him." But according to what Buck Hill told me, he

did take it to them twice for me to be promoted and Gene Everson wouldn't sign

i t.

Between July 1981 and- now or,so, I work,e,d as alpipe fitter (khis.ys

on all the main steam and feedwater except putting it inside the compartment (they3

had another crew who did that).'

We had a fit on the main steam pipe which is 32". The bends were 45 . When

I went to make my fit, we had a gap so they would have to take it about one^MI1nch

on one side to make it fit. I told my foreman and he said 0.K., fine. I told

the men who would have to do it and they were moving their equipment to do it

when Buck Hill came up a asked what we were doing. I told him we were going$

to have to cut the one nch off so it would fit. He said no, that he would

have he engineers shoot it. They shot it three times and finally decided that

the one ch had to come off, just like I had said at first. It took at least

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a month and a half before we ever got it done.

There was a problem on the same main steam line with a weld data card.

The weld data card was lost. It was cut out and refit and redone the way

it should have been done. Later there was another problem on another similar

main steam line whem the weld data card was lost. A new data card was made

up, but it didn't show the fact that two previous repairs had been made on

it. There was a red hold tag for the nonconformance report (NCR 113425 dated1

4/16/82, signed by R. E. Walters) on the pipe because the original weld data

card had been lost. One day I noticed that the red hold tag wasn't on the

pipe any longer. I saw the new weld data card and the two repairs that were

made on it previously were not shown on it. They- should have cut:it out and

redone it the way they did on the other one. They did not go by procedure.

They took the new weld data card to QC and QC just laughed at them because

nothing was verified on it. QC wouldn't approve it. It was taken back to

Buck Hill and he was told that QC wouldn't buy it. The card was left withI' Buck Hill at his instructions. The next morning the card was bought off by

QC, I don't know that the weld isn't good . It may be. But there's no record

of what kind of material went into those two repairs and it didn't indicate

on the new card that the original card had been lost, so nobody knows. The

line number and weld number are: MS-2-RB-19-FW1.

One day Buck Hill and I got into an argument about the main steam line

pipe. He made the statement that carbon pipe (carbon steel pipe) had to be

7500 to move a 1/16 of an inch. I asked him where he'd been all his life and

told him that if he had ever worked in the oil field or put up a barbed wire

fence in the summer time (as I have) he'd know that heat and cold are going to

expand and contract a pipe. On the ground in the oil field, you can see dirt

piled up on each side where the pipe has moved back and forth from the temperature

change. You don't have to be an engineer to figure that out.

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I have been shown a copy of NRC Form 3 (6-82), Notice to Employees, on

which it is stated that " copies of this notice must be posted in a sufficient

number of places in every establishment where activities licensed by the NRC

are conducted, to permit employees to observe a copy on the way to or from their

place of employment." I have never seen a copy of this Notice at Cornanche Peak,to the best of my recollection. I'll try to take a good look when I go back towork tomorrow.

I didn't even know that there was any kind of protection for anyone turning

in any problems to the 'NRC until last week (1/18/83). When I found out that

there was some possibility of -+ action, I decided that I should tell what Iknow about and am concerne?,

dt Comanche Peak. I'm still concerned thatm

they may fire me because I've done this and I want protection from that. I'm

also concerned that th^y .ny fire my son-in-law, Freddy Ray Harrell, may also;

be fired because he is my helper at work and will confinn some of the thingsI've said. I think he should also be protected. I will testify if I am allowed

to in the operating license hearings and so w Jil my son-1,n-law.i

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, s i rb$f ??;' ?Lester Smith

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WDate: January 23, 1983D

5/w. Q fdl Lfitness h

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L'Wi tness ' gN

STATE OF TEXAS E"

On this, the 23rd day of January,1983, personally appeared Lester Smith, known 1

to me to be the person whose name is subscribed to the foregoing instrununt,i

and acknowledged to me that he executed the same for the purposes therein expressed. s:Subscribed and sworn before me on the'23rd day f January,1983. 5

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|.. My Comission Expires: / M d' / Notary Public in anti for the State of Texas 5h5

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